Seymour and Phyllis C. Bronson - Page 12




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          partnership loss, $14,888.  In the statutory notice of deficiency           
          which provides the basis for our jurisdiction in this case,                 
          respondent determined that the Gordon-Wylies are liable for                 
          additions to tax under section 6653(a)(1) and (2) in the                    
          respective amounts of $256 and 50 percent of the interest due on            
          a $5,117 deficiency.  Prior to issuing the notice of deficiency,            
          respondent did not make inquiries of the Gordon-Wylies concerning           
          the proposed adjustments, nor did respondent provide them with an           
          opportunity for an administrative appeal.                                   
          The Garritys                                                                
               During 1983, petitioners James R. Garrity and Sandra T.                
          Garrity assisted in operating a family-run Exxon Service Center.            
          Mr. Garrity has a bachelor’s degree in business and has taken               
          basic courses in taxes and economics.  Mrs. Garrity has a high              
          school education and has no academic background in taxes,                   
          economics, or finance.                                                      
               Mr. Trimboli had been assisting the Garritys and their                 
          family with their personal and corporate tax returns for several            
          years prior to 1983.  The Garritys knew that Mr. Trimboli would             
          likely receive a commission for selling them an interest in Arid            
          Land.  In December 1983, the Garritys purchased five units in               
          Arid Land through Mr. Trimboli for a total of $5,500 in cash and            
          a promissory note of $8,250.                                                








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